n

09'~ SUPERIOR COURT OF NEW JERSEY

LAW DIVISION - CRIMINAL ~~•.

State Grand Jury

Juts ~~t~'G J. J~'f~r~+i, Jr. Number SGJ6 3 7 -13 -13

superior court X 3_ 0 6- 0 0 1 ~0 9- SDocked Num~sr

Es

STATE OF NEW JERSEY ) ~~

V ) _.

. .

TODD P. HALPERN )

GEORGE J. HALPERN )

DAViD ~LTMAN )

JACi~ B . CHESNER )

MIRIAM -CHESNER )

I~ANUEL CRUZ )

GARRY D. LLOYD ) INDICTMENT

HENRY FORD )

DARIO GOMEZ )

AUGUSTIN GOMEZ )

ANDRES LOPEZ I I I ) ~~j~j ~~ ~Q I J

o s ~ R z S PE R~ Z ~ State Grarau Jury dude

and )

EDGARD TORRES )

The Grand Jurors of and for the State of New Jersey, upon

their oaths, present that:

COUNT ONE

(Conspiracy - Second Degree)

TODD P. HALPERN

GEORGE J. HALPERN

DAVID ALTMAN

JACK B. CHESNER

MIRIAM CHESNER

MANUEL CRUZ

CARRY D. LLOYD

HENRY FORD

DARIO GOMEZ

AUGUSTIN GOMEZ

ANDRES LOPEZ III

OSIRIS PEREZ

and

EDGARD TORIES

between on or about October 26, 2008, and on or about May 12,

2fl12, at the City of Trenton, in the County o~ Mercer; at the

Townships of Livingston and Millburn, and at the City of Newark,

all in the County of Essex; at the Borough of Fanwood, at the

Cities of Plainfield and Elizabeth, and at the Township of Union,

all in the County of Union; at the Borough of Morris Plains, in

the County of Morris; at the Cities of Union City and Jersey

City, both in the County of Hudson; at the Township of

-2-

Washington, in the County of Gloucester; at the Township of

Monroe, in the County of Middlesex; at the Township of Lyndhurst,

in the County of Bergen; at the City of Kissimmee, in the State

of Florida; and at the City of Las Vegas, in the State of Nevada,

elsewhere, and within the jurisdiction of this Court, with the

purpose of promoting or facilitating the commission of the crimes

of theft by deception and money laundering, did agree that:

A. One or more of them knowingly would engage in conduct

which would constitute the aforesaid crimes, or

B. One or more of them knowingly would aid in the planning,

solicitation or commission of said crimes, that is:

1. Theft by Deception - one or more of them would

purposely obtain property of another by deception, contrary to

the provisions of N.J.S.A. 2C:20-4;

2. Money Laundering - one or more of them would engage

in transactions involving property known or which a reasonable

person would believe to be derived from criminal activity (1)

with the intent to facilitate the criminal activity; or (2)

knowing that the transactions were designed in whole or in part

to conceal or disguise the nature, location, source, ownership or

control of the property derived from criminal activity, contrary

to the provisions of N.J.S.A. 2C:21-25b(1) and 2C:21-25b(2)(a);

All in violation of the provisions of N.J.S.A. 2~:5-2, and

against the peace of this State, the government and dignity of

the same.

-3-

COUNT TWO

(Money Laundering - First Degree)

TODD P. HALPERN

and other persons whose identities are known and unknown to the

Grand Jurors, who are named as co-conspirators but not as

defendants herein, between on or about October 26, 2008, and on

or about May 12, 2012, at the City of Trenton, in the County of

Mercer; at the Townships of Livingston and Millburn, and the City

of Newark, all in the County of Essex; at the Borough of Fanwood,

at the Cities of Plainfield and Elizabeth, and at the Township of

Union, all in the County of Union; at the Borough of Morris

Plains, in the County of Morris; at the Cities of Union City and

Jersey City, both in the County of Hudson; at the Township of

Washington, in the County of Gloucester; at the Township of

Monroe, in the County of Middlesex; at the Township of Lyndhurst,

in the County of Bergen; at the City of Kissimmee, in the State

of Florida; and at the City of Las Vegas, in the State of Nevada,

elsewhere and within the jurisdiction of this Court, did commit

the offense of money laundering, in that the said TODD P. HALPERN

and others whose identities are known to the Grand Jurors, did

engage in transactions involving property known to be derived

from criminal activity, including theft by deception and identity

theft, with a value in excess of $500,000.00, knowing that the

transactions were designed in whole or in part to conceal or

disguise the nature, location, source, ownership or control of

-4-

the property derived from the said criminal activity, and to

facilitate the criminal activity; that is, TODD P. HALPERN and

others whose identities are known to the Grand Jurors, did file,

cause to be filed, or re-certified fraudulent New 3ersey

Unemployment Claims, received payments on said claims, negotiated

checks associated with said claims, or cased payments from said

claims to be deposited to bank accounts under their control, all

contrary to the provisions of N.J.S.A. 20:21-25b(1) and 2C:21-

25b(2)(a), and N.J.S.A. 2C:2-6, and against the peace of this

State, the government and dignity of the same.

-5-

COUNT THREE

(Identity Theft - Second Degree)

TODD P. HALPERN

between on or about October 26, 2008, and on or about May 12,

2012, at the City of Trenton, in the County of Mercer, at the

City of Livingston, in the County of Essex, elsewhere, and within

the jurisdiction of this Court, with purpose to obtain a benefit

for himself or another in an amount of $75,000.00 or more, or to

injure or defraud another, did impersonate five or more persons

or assume five or more false identities and did acts in such

assumed characters or false identities, that is, the said TODD P.

riALeERiv dici iiiipersonate or assume ine identities vi "V. A. ,

~~L.D. ~„ ~~P.W. ~„ .~S.D. ~„ .~J.D. ~„ .,S.E. ~„ ~~F.G. ~., .,J.G. ~„ .~M.M. ~.~

.,J.M. ~ ~~ ~~S.M. ~„ .~~, W ~„ ,~L B ~,~ .~A.C. ~„ .~R.L. ~„ .~S.I. ~., ~~D.T. ~„

"E.P.," and "J.T.," and file for and collect unemployment

insurance benefits in these names from the State of New Jersey

with an aggregate value in excess of $75,000.00, contrary to the

provisions of N.J.S.A. 2C:21-17(a)(1), N.J.S.A. 2C:21-17(c)(3),

and N.J.S.A. 2C:2-6, and against the peace of this State, the

government and dignity of the same.

COUNT FOUR

(Theft by Deception - Second Degree)

TODD P. HALPERN

and

DAVID ALTMAN

between on or about October 26, 2008, and on or about May 12,

2012, at the City of Trenton, in the County of Mercer; at the

Townships of Livingston and Millburn, and at the City of Newark,

all in the County of Essex; at the Borough of Fanwood, at the

Cities of Plainfield and Elizabeth, and at the Township of Union,

all in the County of Union; at the Borough of Morris Plains, in

the County of Morris; at the Cities of Union City and Jersey

City, both in the County of Hudson; at the Township of

Washington, in the County of Gloucester; at the Township of

Monroe, in the County of Middlesex; at the Township of Lyndhurst,

in the County of Bergen; at the City of Kissimmee, in the State

of Florida; and at the City of Las Vegas, in the State of Nevada,

elsewhere, and within the jurisdiction of this Court, purposely

did obtain property of the State of New Jersey having an

aggregate value of $75,000.00 or more, by deception, that is, the

said TODD P. HALPERN and DAVID ALTMAN purposely did obtain

unemployment insurance benefits by filing, causing to be filed,

or receiving payments on fraudulent applications for unemployment

insurance benefits filed with the State of New Jersey, thereby

-7-

creating or reinforcing false impressions to the State of New

Jersey that the individuals in whose names said claims were filed

had earned wages from employers during certain time periods, and

that they were entitled to collect unemployment insurances

benefits from the State of New Jersey;

WHEREAS IN TRUTH AND IN FACT, as the said TODD P. ~ALP~RN

and DAVID ALTMAN well knew; said individuals were not employed by

the employers named in said unemployment insurance applications

during the time periods indicated, nor had they earned the wages

indicated, and were thereby not entitled to collect said

unemployment insurance benefits from the State of New Jersey, all

contrary to the provisions of'N.~.S.ti. 20:20-~, N.J.S.A. 2C:2u-

2b(1)(a), and N.J.S.A. 2C:2-6, and against the peace of this

State, tie government and dignity of the same.

COUNT FIVE

(Money Laundering - Second Degree)

DAVID ALTMAN

between on or about September 19, 2010, and on or about March 28,

2012, at the City of Trenton, in the County of Mercer, at the

Borough of Fanwood, in the County of Union, elsewhere and within

the jurisdiction of this Court, did commit the offense of money

laundering, in that the said DAVID ALTMAN did engage in

transactions involving property mown to be derived from criminal

activity, including theft by deception, with a value in excess of

$75,000.00, knowing that the transactions were designed in whole

or in part to conceal or disguise the nature; location; source,

ownership or control of the property derived from the said

criminal activity, or to facilitate the criminal activity; that

is, the said DAVID ALTMAN did file, cause to be filed, or re-

certified fraudulent New Jersey Unemployment Claims, received

payments on said claims, negotiated checks associated with said

claims, caused payments from said claims to be deposited to a

bank account under their control, all contrary to the provisions

of N.J.S.A. 2C:21-25b(1) and 2C:21-25b(2)(a), and N.J.S.A. 2C:2-

6, and against the peace of this State, the government and

dignify of the same.

-9-

COUNT SIX

(Theft by Deception - Third Degree)

JACK B. CHESNER

MIRIAM CHESNER

MANUEL CRUZ

HENRY CORD

DARIO GOMEZ

AUGUSTIN GOMEZ

GEORGE J. HALPERN

CARRY D. LLOYD

ANDRES LOPEZ III

OSIRIS PERES

and

EDGARD TORRES

between on or about April 19, 2009, and on or about February 5,

2fl12, at the City of Trenton, in the County of Mercer; at the

Townships of Livingston and Millburn, and at the pity of Newark,

all in the County of Essex; at the Cities of Plainfield and

Elizabeth, and at the Township of Union, all in the County of

Union; at the Borough of Morris Plains, in the County of Morris;

at the Cities of Union City and Jersey City, both in the County

of Hudson; at the Township of Washington, in the County of

Gloucester; at the Township of Monroe, in the County of

Middlesex; at the Township of Lyndhurst, in the County of Bergen;

at the City of Kissimmee, in the State of Florida; and at the

City of Las Vegas, in the State of Nevada, elsewhere, and within

the jurisdiction of this Court, purposely did obtain property of

the State of New Jersey having an aggregate value of $500 or

more, by deception, that is, the said JACK B. CHESNER, MIRIAM

CHESNER, MANUEL CRUZ, HENRY FORD, DARIO GOM~Z, AUGUSTIN GOMEZ,

GEORGE J. HALPERN, GARRY D. LLOYD, ANDRES LOPEZ III, OSIRIS

PEREZ, and EDGARD TORRES purposely did obtain unemployment

insurance benefits by filing, causing to be filed, or receiving

payments on applications for unemployment insurance benefits

filed with the State of New Jersey, thereby creating or

reinforcing false impressions to the State of New Jersey that

they had earned wages from employers during certain time periods,

and that they were entitled to collect unemployment insurance

bAnefits from the State of New Jersey]

WHEREAS IN TRUTH AND IN FACT, as the said JACK B. CHESNER,

MIRIAM CHESNER, MANUEL CRUZ, HENRY FORD, DARIO GOMEZ, AUGUSTIN

GOMEZ, GEORGE J. HALPERN, GARRY D. LLOYD, ANDRES LOPEZ III,

OSIRIS PEREZ, and EDGARD TORRES well knew, they had not been

employed by the employers named in said unemployment insurance

applications during the time periods indicated, nor had they

earned the wages indicated, and were thereby not entitled to

collect said unemployment insurance benefits from the State of

New Jersey, all contrary to the provisions of N.J.S.A. 2C:20-4,

N.J.S.A. 2C:20-2b(1)(a), and N.J.S.A. 2C:2-6, and against the

peace of this State, the government and dignity of the same.

-11-

COUNT SEVEN

(Money Laundering - Third Degree)

JACK B. CHESNER

MIRIAM CHESNER

MANUEL CRUZ

HENRY FORD

DARIO GOMEZ

AUGUSTIN GOMEZ

GEORGE J. HALPERN

GARRY D. LLOYD

ANDRES LOPEZ III

OSIRIS PERES

and

EDGARD TORRES

between on or about April 19, 2009, and on or about February 5,

2012, at the City of Trenton, in the Cou~t~ of Mercer; at the

Townships of Livingston and Millburn, and at the City of Newark,

all in the County of Essex; at the Cities of Plainfield and

Elizabeth, and at the Township of Union, all in the County of

Union; at the Borough of Morris Plains, in the County of Morris;

at the Cities of Union City and Jersey pity, both in the County

of Hudson; at the Township of Washington, in the County of

Gloucester; at the Township of Monroe,- in the County of

Middlesex; at the Township of Lyndhurst, in the County of Bergen;

at the City of Kissimmee, in the State of Florida; and at the

City of Las Vegas, in the State of Nevada, elsewhere and within

the jurisdiction of this Court, did commit the offense of money

laundering, in that the said JACK B. CHESNER, MIRIAM CHESNER,

-12-

MANUEL CRUZ, HENRY FORD, DARIO GOMEZ, AUGUSTIN GOM~Z, GEORGE J.

HALPERN, CARRY D. LLOYD, ANDRES LOPEZ III, OSIRIS ~EREZ, and

EDGARD TORRES did engage in transactions involving property known

to be derived from criminal activity, including theft by

deception, knowing that the transactions were designed in whole

or in part to conceal or disguise the nature, location, source,

ownership or control of the property derived from the said

criminal activity, or to facilitate the criminal activity; that

is, the said JACK B. CHESNER, MIRIAM CHESNER, MANUEL CRUZ, HENRY

FORD, DARIO GOMEZ, AUGUSTIN GOMEZ, GEORGE J. HALPERN, CARRY D.

LLOYD, ANDRES LOPEZ III, OSIRIS PEREZ, and EDGARD TORRES did

file, cause to be filed, or re-certified fraudulent New Jersey

Unemployment Claims, received payments on said claims, negotiated

checks associated with said claims, or caused payments from said

claims to be deposited to a bank account under their control, all

contrary to the provisions of N.J.S.A. 2C:21-25b(1) and 2C:21-

25b(2)(a), and N.J.S.A. 2C:2-6, and against the peace of this

State, the government and dignity of the sam .

Elie Honig, Dire r

Division of Criminal Justice

~ TRUE BILL:

1J~~ Foreperson

Dated: ~ /~ /~-~

-13-

r ~ SUPERIOR COURT OF NEW JERSEY

n LAw DIVISION — CRIMINAL - f

~CE~ V G~ --- ,F

State Gra d Jury ~ _ '. ~€ ~~~ ~ ~ ~~~~ Number'~SGJ637-13-13

Superior Court

,Ju~~e~o~..i~ir~~.,,k. Docket Number 1 3- 0 b- 0 0 1 0 9- Sf ~

~, ~STATE OF NEW JERSEY ) ~' ~

:̀r~- _~

V.

TODD P. HALPERN )

GEORGE J. HALPERN )

DAVID ALTMAN )

JACK B. CHESNER )

MIRIAM CHESNER )

MANUEL CRUZ )

GARRY D. LLOYD )

HENRY FORD )

DARIO GOMEZ )

~,UGUSTIN GOMEZ )

ANDRES LOPEZ III )

OSIRIS P~REZ )

and )

EDGARD TORRES )

ORDER OF VENUE

State Gra~~~ Jury Judge

An Indictment having been returned to ~~is Court by the

State Grand Jury in the above captioned matter,

IT IS ORDERED on this ~l~g day of ✓~-~ 2013,

pursuant to paragraph 8 of the State Grand Jury Act, that the

County of Mercer be and hereby is designated as the County of venue

for the purpose of trial.

IT IS FURTHER ORDERED that the Clerk of the Superior Court

shall transmit forthwith the Indictment in this matter and a

certified copy of this Order to the Criminal Division Manager of

the County of Mercer for filing.

G / \ / '✓f ,/~./ '/

dro J. Jimenez, Jr. J.S.C.